Ban on the supply and sale of wet wipes containing plastic: Final Business and Regulatory Impact Assessment

Section 3: Costs, impacts and benefits

Quantified costs to businesses

This section will focus on costs of the preferred option (Option 1). The information in this section has been taken from the Economic Annex, produced for the UK-wide consultation on the proposed ban, both of which can be read at https://consult.defra.gov.uk/wet-wipes-1/wet-wipes-containing-plastic and from the final Impact Assessment published by Defra following the consultation, which can be read at https://www.legislation.gov.uk/ukia/2025/197/pdfs/ukia_20250197_en.pdf

Information and data presented is at the UK level. Information for individual nations is not available. It should be noted that through the consultation and via engagement with stakeholders, three businesses that have manufacturing facilities in Scotland were identified^[14]. These companies produce healthcare and / or industrial wipes and supply business-to-business only, and would therefore not be impacted by the ban as set out in this BRIA.

Market Overview

A Defra commissioned report by Valpak^[15] estimated the number of wet wipes placed on the market in the UK. Valpak analysed the market between 2012-2021 using their Environment Product Information Centre (EPIC) database^[16]. This includes: product data from three large supermarket chains equating to over 50% of the UK grocery retail market by sales value; and two wholesale and catering distribution producers equating to 33% of the catering / foodservice (wholesale) channel market share. They also engaged with key stakeholders such as EDANA UK and Recoup. This data was then scaled up to estimate the whole market. They estimate that 31 billion wet wipes were placed on the market in 2021.

Table 1 shows the total individual wet wipes sold in the UK. Childcare wipes make up over half of all wet wipe sales, with just under 18.5 billion (60%) placed on the market in 2021.

Valpak state that 96% of wet wipe sales captured in their estimates are from retail sources, with the remaining 4% from wholesale. Based on discussions with industry stakeholders, this data does not appear to account for the full domestic market and likely only represents sales to consumers. International evidence suggests that globally, business-to-business or industrial use wet wipes make up 20% of the market^[17]. Key industry stakeholders were unable to provide specific data, but agreed that 20% was likely to be representative of the UK market. It was therefore assumed that the Valpak estimate represented 80% of total wet wipes sold in the UK (those sold to consumers), and this was scaled up to include business-to-business wet wipe sales.

The business-to-business estimate is assumed to include industrial, including manufacturing, as well as medical. Industry stakeholders agreed with this assumption. The proportion of business-to-business medical use wet wipes was estimated using data from NHS supply chain in England. Their figures were scaled up to include private facilities based on an estimate of the proportion of medical care provided by the NHS (87%) compared to private facilities^[18], and then scaled up to the UK level using population statistics, with England assumed to make up 84% of the total UK^[19]. This results in an estimated total medical wet wipe sales for the UK in 2021 as 3.4 billion.

Using Valpak’s placed on the market analysis, it is estimated that the number of wet wipes sold in the UK between 2012 and 2021 grew at 2.1% per year. This is then used to estimate future growth. By 2033 it is estimated that 49 billion wet wipes will be used in the UK, with 39 billion of these sold to consumers.

Valpak estimate that approximately 2.5% of consumer wet wipes were imported in 2021. There are limitations to the data used as it only captures source data from the reporting businesses. Therefore, if a product was imported earlier in the supply chain (for example, the final retailer sourced the product from a UK wholesaler that imported the product) this would not be picked up. However, stakeholders have advised that larger retailers in the UK tend to source wet wipes directly from manufacturers. This was backed up by consultation responses, with three quarters (78%) of retail respondents (excluding those that answered “don’t know”) stating they entirely or mostly source wet wipes directly from manufacturers. As discussed above, 96% of wet wipes sales captured in Valpak’s data are from retail sources. It is also known that large wet wipes manufacturers have factories in the UK. This suggests that although there are some limitations to Valpak’s estimate, their conclusion that the proportion of wet wipes imported would be low appears to be backed up by evidence elsewhere. So as not to underestimate the UK manufacturing industry we therefore use Valpak’s estimate and assume that 2.5% of wet wipes are imported. For the purpose of this analysis, this proportion is applied to both consumer and business-to-business (B2B) wet wipes.

UK wet wipe manufacturers have also told us that producing for export is a key part of their business. Within free text responses in the consultation several manufacturers stated that they export a significant proportion of the wet wipes they produce. Of those that provided figures, this ranged between 20-50% of their total sales. Similar estimates were provided by industry stakeholders outside the consultation process (although there may be some overlap). For the purpose of this analysis, the mid-point (35%) was used as the central estimate of the proportion of wet wipes manufactured in the UK that are exported.

We therefore estimate that UK manufacturers produce 61 billion wet wipes, of which 32 billion are for sale to UK consumers, 8 billion sold for business use, and 21 billion exported (as of 2024).

These estimates capture all wet wipes and include plastic and plastic-free wipes. The economic annex accompanying the consultation estimated the proportion of plastic wet wipes based on analysis in the Valpak report. The Valpak report outlines the difficulties in determining the proportion of wet wipes that are plastic due to businesses not being required to include the plastic content on labels. Only a quarter of the products reviewed by Valpak included information on whether they contained plastic. As a consequence, assumptions had to be made on the proportion of the remaining three quarters that contained plastic. This significantly reduced the certainty in the estimates. Relevant questions were therefore asked in the consultation to gain more robust data.

Manufacturers responding to the consultation were asked to provide an estimate of the proportion of wet wipes they produce for the UK market that contain plastic. The mean response was close to 50%. As this was not a weighted average, responses were filtered to include only medium and large businesses^[20] as stakeholders have informed us that a small number of larger businesses produce the majority of wet wipes for the UK market by volume and their responses would be more representative of the total market. This led to a mean response rate of approximately 40%. This was supplemented with other evidence, including publicly available analysis by wet wipes producer Nice-Pak, that estimate that 25% of baby wipes (which make up 60% of consumer wet wipes) contain plastic^[21]. 25% and 50% were therefore assumed to be the extreme low and high, respectively, with the midpoint of 37.5% used as the central estimate. This is lower than the approximately 60% figure used in the economic annex conducted prior to the consultation, but is assumed to be more robust. As we have no data on the split across categories, this is applied equally across all wet wipe types.

Through the consultation, businesses were asked to provide the proportion of plastic wet wipes they supply or sell in each UK nation. Answers provided were analysed to estimate the amount of wet wipes sold in each nation. As shown in Table 3, the average split of sales in each nation was not significantly different to population proportions. This suggests that the proportion of plastic wet wipes sold in each nation does not differ significantly.

Wet Wipe Producers

ONS data was used to estimate the number of businesses by size. As there isn’t a single Standard Industrial Classification (SIC) representative of the wet wipe manufacturing industry, alternative SICs had to be identified to represent the industry. This was done through searching Companies House for the registered SIC codes of a sample of large wet wipe manufacturers, as well as reviewing answers to the consultation where businesses were asked about which SIC codes are most likely to be impacted by the ban. The following SICs were identified as most relevant:

• 13.95 Manufacture of non-wovens and articles made from non-wovens, except apparel
• 17.22 Manufacture of household and sanitary goods and of toilet requisites
• 20.4 Manufacture of soap and detergents cleaning and polishing preparations perfumes and toilet preparations
• 20.56 Manufacture of other chemical products not elsewhere classified

Using ONS data^[22], the total number of businesses (22,000) and total industry turnover (£49 billion) across these SICs^[23] were used to estimate the average turnover per producer (£2.2 million). This was divided by an internally derived estimate of the total industry revenue from producing wet wipes (£1.5 million) to determine the number of wet wipes. The method used to estimate UK wet wipe producers involved multiplying the total number of wet wipes produced by the average retail price to find total wet wipe retail revenue, and then removing the retail and wholesale markups, which were estimated using ONS data.

The high fixed capital costs associated with producing wet wipes favour larger businesses that can take advantage of producing at scale, to minimise the price per unit. Stakeholders have informed us that smaller producers are therefore more likely to produce specialist or niche products or compete other than on price. Specifically, stakeholders identified that small and micro producers are likely to either produce specialist industrial wipes or plastic-free consumer wipes (competing on environmental credentials).

Further views on the structure of the market were sought through the consultation. Industry respondents were asked whether they agreed with turnover splits by business size presented in the consultation were representative of the wet wipe industry. These were based on ONS data^[24] and the manufacturing SIC code. Based on these proportions, medium and large businesses make the vast majority (86%) of industry turnover. Discussions with industry stakeholders, including the wet wipe industry trade body EDANA, informed us that a very small number of large firms produce the majority of wet wipes (on a volume basis) for the UK market.

Based on this consultation analysis, desk-based research and wider stakeholder analysis, it can be concluded that it is unlikely that small and micro producers would be impacted by the ban as currently designed. The impacts would fall on a relatively small number of medium and large producers.

An estimate of the number of producers impacted by the ban was produced. Overall, 22 UK wet wipe producers were identified, the majority of which are medium and large. Of these, 18 were identified as producing consumer wet wipes, of which five already produce only plastic-free wet wipes. This left four medium, and nine large producers that would be impacted by the ban (as they currently produce wet wipes containing plastic). Note that this calculation excludes large retailers selling own brand products as stakeholder engagement confirmed that these would be considered “rebranders”, i.e. they don’t own wet wipe production equipment and source their wet wipes from other manufacturers, although it does include micro businesses that describe themselves as manufacturers but were identified to be “rebranders”.

Although it cannot be guaranteed that this accounts for every relevant UK producer, the breadth of stakeholder engagement provides confidence that it is representative of the sector. However, due to this small remaining uncertainty, an earlier estimate of 30 producers impacted by the ban has been used within the analysis. Based on the split of four medium and nine large businesses, we estimate that 69% of these businesses are large.

Through stakeholder engagement and via the consultation, we have identified three manufacturers with facilities in Scotland. As noted, these companies produce healthcare and / or industrial wipes and supply business-to-business only, and would therefore not be impacted by the ban as set out in this BRIA.

Wet Wipe Retailers

The economic annex published alongside the public consultation listed a number of retail SICs expected to be impacted by the ban. Consultation respondents were asked whether they agreed or disagreed with the SICs identified, and asked to provided further relevant SICs if the latter. Based on these responses, the following retail SICs were assumed to be impacted by the ban:

• 4711. Retail sale in non-specialised stores with food, beverages or tobacco predominating
• 4719. Other retail sale in non-specialised stores
• 4744. Retail sale of cosmetic and toilet articles in specialised stores
• 4775. Retail sale of medical and orthopaedic goods in specialised stores

ONS data^[25] was used to find out how many businesses by size are in these SICs in the UK as a whole. The combined total across all sizes of business is 44,440.

Potential impacts, benefits to business, and other impacts

This section will discuss possible impacts to business, if a ban were to come into force (Option 1), including the topics of:

• Producer profit
• Transition costs
• Impacts on small and micro businesses

If Option 2 or 3 were enacted, i.e. a ban did not come into force, there would be no additional costs or savings to business.

Business impacts

Producer profit (wet wipe producers)

A ban, as outlined in this BRIA, would have a direct impact on businesses producing plastic wet wipes leading to reduced profit (through no longer producing plastic wet wipes for the UK consumer market). There is potential that some producers may cease production, however it is expected that producers will move to the next most profitable alternative, which for most, would be to produce plastic-free wet wipes^[26]. It is acknowledged that any switch in production may result in lower total profit, otherwise producers would have already made this switch. But it is reasonable to expect a proportion of the lost profit to be recouped through production of other items. Profit from production of additional plastic-free wet wipes would be considered an indirect impact.

Producer profit is a function of their total revenue from wet wipes and the costs to produce wet wipes. The following approach was used to estimate producer revenue from wet wipes. First, retail revenue was estimated. This was done by taking the average price per wet wipe and multiplying it by the number of wet wipes sold. Note that as the aim is to estimate UK producer profit^[27], only the number of wet wipes sold in the UK produced by UK manufacturers was used.

The average price per wet wipe was estimated as 5p per wipe, using findings from the Valpak report^[28]. Valpak reviewed products sold by three major UK supermarkets, as well as major retail chains and found the maximum and minimum price per wet wipe for each wet wipe product category. A weighted average of these costs, based on the sales share of each category was calculated.

Having estimated the retail revenue from the sale of wet wipes in the UK, the retail markup (gross profit) was then removed. The retail markup was calculated using Annual Business Survey (ABS) Data^[29] for SIC code 47 “Retail trade, except of motor vehicles and motorcycles”. Turnover net of purchases of goods, materials and services, was calculated as a proportion of turnover (averaged over 5 years) giving an estimated retail markup of 21%.

The same method was used to estimate wholesale markup, however this was adjusted to account for the assumption that the majority of retailers source wet wipes directly from producers. SIC code 46 “Wholesale trade, except of motor vehicles and motorcycles” was used, with a markup of 14% estimated. 78% of retailers responding to the consultation stated that they entirely or mostly source wet wipes directly from producers. It was therefore assumed that only 22% of wet wipes are sourced via wholesale.

Removing the retail markup from retail revenue equates to the wholesale revenue, if 100% of wet wipes are sourced through wholesalers. Multiplying this by the proportion of wet wipes sourced through wholesalers (22%) leads to the actual wholesale revenue (the remaining 78% is essentially the revenue to producers when wipes are sold directly to retailers). Multiplying this by the wholesale markup then produces the wholesale markup value. Removing the retail and wholesale mark-up values from retail revenue equates to combined producer revenue from selling via wholesalers and directly to retailers.

Producer revenue was then divided by the number of wet wipes sold to find the average producer revenue per wet wipe. Again, the manufacturing markup was removed from this to estimate the input cost (i.e. excluding employment costs) of producing wet wipes. The average of the four SIC codes discussed earlier was used to estimate this.

Through the consultation, producers told us that input costs for plastic-free wet wipes tend to be higher than for wet wipes containing plastic. Figures provided by manufacturers ranged from a 5% increase to 3 times higher costs with a median increase of 40%. We therefore estimated a separate production cost per wet wipe for plastic containing, and plastic-free, wet wipes. It is possible that this differential could decrease over time due to economies of scale or innovation, however as we have no evidence on the scale of any savings, this analysis assumes it will remain constant over the appraisal period.

Estimating these costs was done by finding the respective cost per wipe needed for each product (plastic / plastic-free) to meet the requirement that plastic-free wipes cost 40% more than plastic to produce, and multiply to the total producer cost estimated, when the share of plastic vs plastic-free is accounted for. It is assumed that the plastic content would not impact employment costs as, through the consultation, most producers stated that the same processes would be used to produce plastic and plastic-free wet wipes (see the transition costs section for more details).

Through internal research and stakeholder engagement we found evidence that the retail price that the customer could pay for plastic-free wet wipes tends to be slightly higher than plastic wet wipes, on a like-for-like basis. Two large retailers, that outsource production of their own-brand wipes (and are essentially “rebranders”), confirmed that when they switched their own brand products from plastic to plastic-free, they experienced an increase in the cost of sourcing these wipes (although one retailer was able to internalise these costs and retain the previous retail price). This suggests that retail price increases are related to increased sales prices from producers. Both internal research and discussions with retailers concluded a 10% increase in retail prices for wet wipes on a like-for-like basis.

This 10% increase in producer revenue per wipe is included in the profit to producers (per wipe) for plastic-free wipes. A similar approach was used to estimate costs, whereby the respective revenue per wipe was found which satisfied the criteria that revenue per wipe is 10% higher for plastic-free wipes, and that the total revenue for all wipes must equate to previously estimated baseline total producer revenue.

By estimating the total cost per wipe, as well as the revenue per wipe, this allowed for an estimate of the producer profit per wipe for plastic and plastic-free wet wipes. This was then multiplied by the number of plastic and plastic-free wet wipes in each scenario to estimate the profit from each (Table 5).

Transition costs (wet wipe producers)

These costs relate to the transition from producing plastic containing to plastic-free wet wipes. 68% of manufacturers responding to the consultation stated that producing plastic-free wet wipes used the same machinery and general processes as producing wet wipes containing plastic. This removes the need for these producers to purchase new machinery, however producers did name other costs they expect to incur, such as research and development, more minor adjustments to machinery, legal work, and training of staff.

Within free text responses, several producers highlighted that a longer transition period would reduce their costs. One producer stated that costs under a one to two year transition period would be 50% of those under a transition period of less than a year. Another producer also stated that a transition period of two to three years would lead to lower costs. By including an 18-month transition period within the regulation (Option 1) we therefore expect this to reduce transition costs compared to a shorter transition period.

Through the consultation, producers were asked to provide an estimate of the cost they would face to transition to only producing plastic-free wet wipes. The mean cost per business was then estimated from these responses. It was identified that producers that stated they could not use the same machinery to produce plastic-free and plastic containing wet wipes reported higher transition costs. A separate average was therefore estimated for those that said they could and could not use the same machinery. The average for those that said they could use the same machinery was £1.8 million per business. The average for those that stated they could not use the same machinery was £11.45 million. The weighted average cost per business, based on 68% of producers being able to use the same machinery, was estimated to be £4.89 million. Note that these costs were provided by a mixture of medium and large producers.

These costs were provided on the basis of a ban on manufacturing which would have banned the production of wet wipes for export as well as UK domestic use. Through free text responses in the consultation, a significant number of producers told us that costs would be significantly higher if the ban included restrictions on producing wet wipes containing plastic for export. Producers also told us that they tend to export 20-50% of the wet wipes they produce. As noted earlier, the mid-point (35%) of this range was used as the proportion of wet wipes exported by UK producers. To account for the fact that the ban will only apply to the supply and sale of wet wipes to UK consumers, the cost per business was adjusted down by the export proportion of wet wipe production. This led to an estimate of £3.18 million per business.

As discussed above, it is estimated that 30 producers across the whole UK will be impacted by the ban and will transition to selling only plastic-free wet wipes. This implies transition costs of £94 million in total to these UK wet wipe producers. These costs would be spread over the transition period. As noted previously, three wet wipe producers in Scotland have been identified, all of which produce wet wipes for the business-to-business market.

Transition costs (retailers)

An 18-month transition period (Option 1) is expected to allow retailers enough time to sell off excess stock and replace products within their usual product review cycle and therefore costs to retailers will be minimal. This was supported in part by consultation responses, however the number of retail business responding to questions on the cost of transition was low, and those that did respond generally did not provide much information on costs. One retailer stated that costs would be lowest under a two to three year transition period. A large retailer that has already made the transition stated that they were able to make the switch within a year, and that costs were minimal. Several retailers stated the costs were unknown, and two other retailers that had already made the transition stated the cost would be zero for them.

However, to ensure that costs were not being underestimated, the cost of updating stocklist and prices for new products was calculated. As no specific costs were provided by retailers through the consultation, relevant approaches used in analysis elsewhere were reviewed to find an appropriate means to estimate costs. It is assumed costs will be proportional to the number of plastic wet wipe products sold. The websites of four large retailers were reviewed to determine the number of individual product lines sold by each retailer. This was specifically done for baby wipes, which make up 60% of the consumer wet wipe market. On average, these retailers had 33 individual baby wipe products. This was scaled up by the baby wipe market share to estimate the number of total wet wipe products (55). It was assumed that 38% of these would contain plastic (based on our estimated plastic wet wipe share of total wet wipes, as noted above), which led to an estimate of 20 plastic wet wipe product lines per large retailer.

It is assumed that smaller retailers will carry fewer products. A cautiously high approach was used whereby large retailers were assumed to carry 20 plastic wet wipe products, medium to carry 15, small to carry 10, and micro to carry 5. Based on stakeholder feedback, a carrier bag charge impact assessment assumed it would take one and a half hours of time per product line, per store, to add a new product line^[30]. This same assumption has been applied, as has the median retail wage for 2023 of £11.43 (in 2019 prices)^[31], with a 22% uplift for non-wage labour costs. This led to an estimate of around £100 to £400 per store, depending on the size of the store, to add new plastic-free wet wipes product lines following a ban.

Small business impacts

The UK Government conducted individual engagement interviews with relevant businesses prior to and during the consultation period, as well as conducting group information sessions during and after the consultation period. These businesses included manufacturers and retailers, including those operating in Scotland.

Under the ban presented as Option 1, wet wipe producers will be banned from supplying wet wipes containing plastic for sale to consumers in the UK. Those producers that manufacture wet wipes for medical or industrial uses, and supply on a business-to-business basis, will not be affected by the ban as it is presented in this BRIA. As noted previously, through the consultation and via engagement with stakeholders, three businesses that have manufacturing facilities in Scotland were identified. These companies produce healthcare and/or industrial wipes and supply business-to-business only.

Producers have informed us that plastic-free wet wipes cost more to produce than plastic wet wipes which will lead to higher production costs, and potentially a loss of profits. Based on research conducted and stakeholder engagement at the UK level it is concluded additional costs will fall entirely on medium and large wet wipe producers. 69% of producers identified as likely to be selling products that will be banned are large businesses. It is concluded that there are unlikely to be small and micro businesses impacted by the ban. This is because stakeholders have told us that wet wipe manufacturing involves high fixed capital costs, which the smallest businesses would not be able to afford, and better suits large businesses that can produce in bulk. Stakeholders informed us that smaller businesses are more likely to produce specialist industrial wipes or compete on environmental credentials, rather than price (and already produce only plastic-free wipes). Furthermore, micro producers are more likely to be “rebranders” (as previously described), which is likely linked to the high cost of capital. None of the six small and micro producers involved in stakeholder engagement (including the consultation) would be impacted by the ban in Scotland and across the rest of the UK, as presented in the joint government response to the consultation, and as is outlined here as Option 1.

Small and micro retailers make up 99% of total retail businesses across the UK and make 21% of retail industry turnover. Assuming that sales of wet wipes are roughly correlated with turnover, this would suggest that small and micro retailers sell around a fifth of all wet wipes. Excluding these businesses would therefore significantly reduce the impact of the ban and the environmental and health benefits expected to be realised. Exempting these businesses has therefore been disregarded.

As discussed above, costs to retailers are expected to be minimised by the 18-month transition period. This will allow retailers time to sell through stock and replace product lines. As noted previously, transition costs are calculated on a per store basis, and based on the size of the store. Average costs have been calculated as less than 0.1% of total revenue for all sizes of business in England, and it can be assumed that similar costs would be incurred by all sizes of businesses across the UK as a whole.

Scottish firms’ international competitiveness

As the proposed ban will not affect manufacturing and export, it is not expected that this would have a significant impact on the ability of Scottish businesses to compete internationally, nor will it affect Scotland’s attractiveness as a destination for global capital investment. Through the consultation and via engagement with stakeholders, three businesses that have manufacturing facilities in Scotland were identified. These companies produce healthcare and/or industrial wipes and supply business-to-business only, and would be able to continue to manufacture and export their goods after the proposed ban is introduced.

Investment

As the proposed ban will not affect manufacturing and export, it is not considered that its introduction will have a measurable effect on making Scotland a more, or less, attractive place for global investment.

Workforce and Fair Work

As noted above, as identified businesses in Scotland will not be impacted by the proposed ban, there would be no expected impact on the workforce. The ban would not have any direct impact on Fair Work First principles.

Climate change / Circular Economy

The proposed ban will help prevent plastic litter entering the environment, and will help prevent micro and nano plastic pollution in our seas. A ban would contribute to efforts by the Scottish and UK governments to work toward GES under the UK Marine Strategy, and contribute to other commitments to protect the marine environment. There would be no increase on the recycling of resources. Carbon emissions related to both manufacturing and degradation once disposed of are likely to decrease if plastics were not a component of these products.

Competition assessment

As aforementioned, the ban is predicted to increase costs to producers. Respondents to the consultation have informed us that input costs to produce plastic-free wet wipes are higher than those to produce wet wipes containing plastic. Increasing costs could cause producers to exit the market. Increasing costs could also lead to barriers to enter to the market.

However, the costs to producers are not thought to be prohibitive. A significant proportion (62%) of wet wipes are already plastic-free, and we estimate that the total cost to wet wipe producers represents up to 3% of total revenue to the sector on average per year. As such, this is not expected to be a significant risk. As discussed above, evidence from stakeholder engagement suggests that consumer wet wipes containing plastic are produced exclusively by medium and large businesses, which minimises the risk of small and micro businesses going out of business due to excessive burden from the ban.

Through the consultation, producers communicated their concern that a ban on manufacturing plastic wet wipes for export could lead to businesses becoming unsustainable and exiting the market. As UK producers that export also produce for the UK market this could have reduced the number of suppliers to the domestic market. However, the Scottish Government has decided that the ban will only apply to the supply and sale of wet wipes containing plastic (Option 1). The other nations of the UK have made the same decision, with the result that the ban will only apply to the supply and sale of wet wipes containing plastic to consumers across the UK. This reduces the risk of producers exiting the market from a loss of export sales.

The ban will inherently limit the characteristics of products supplied by prohibiting the use of plastic. However, as discussed, there are already a variety of suitable alternatives on the market. Plastic-free products are already produced by a number of different brands, with a range of different products on the market.

It is likely that the ban would lead to additional innovation. The ban will require producers to determine the best natural materials with the required properties to use for their individual products. It may also provide incentives for producers to try to gain a competitive advantage through research into higher quality and more robust alternatives to plastic. This was confirmed by producers that, through the consultation, stated that a ban would require spending on research and development.

As discussed, it is expected that the ban will increase the cost to produce wet wipes on a like-for-like basis. It is possible that this will translate into higher prices. However, suppliers already supply low-cost plastic-free wet wipes. As highlighted above, of four large retailers reviewed, the lowest priced baby wipes (own brand version) were all already plastic-free. These retailers also sold high cost branded plastic-free wet wipes.

Overall, the limits placed on what suppliers can produce are not anticipated to significantly reduce their ability to compete, or reduce the variety of products available. Furthermore, the ban is not expected to make it easier for businesses to collude.

The ban will remove consumer ability to choose to buy wet wipes containing plastic. However, consultation responses suggest that the public are supportive of a ban and feel that plastic-free alternatives are suitable for their needs. As discussed, it is anticipated that there will still be significant choice for consumers.

The ban will remove the confusion that arises from current labelling practices regarding the plastic content of wet wipes. Currently wet wipes are not required to advertise their plastic content on their packaging, making it difficult for consumers to choose to buy plastic-free wet wipes. The research carried out by Valpak found that only a quarter of wet wipe products reviewed stated either way whether they contained plastic. The ban will provide consumers with the confidence that they are purchasing plastic-free wipes.

Consumer duty

Consumers may be impacted initially by a reduction in product choice as plastic wet wipes are removed from the market. This impact is expected to reduce over time as some producers switch to producing wet wipes that do not contain plastic. Evidence from commissioned work suggests that there is not a significant retail price difference between wet wipes that contain plastic and those that do not. Therefore, we do not expect there to be any direct price impacts on consumers over the long term. Furthermore, stakeholder engagement has indicated that retailers have not received negative feedback from customers regarding alternative products to wet wipes that contain plastic. Certain questions in the consultation gave an opportunity for respondents to fill in free text boxes. Analysis of these responses showed that the second most common theme was that respondents considered plastic-free wipes to be just as good as wet wipes containing plastic.

It is assumed that any additional costs to businesses resulting from the ban will be internalised by those businesses. However, it is possible that businesses will pass some, or all, of these costs onto consumers. The extent to which retailers can pass cost increases on to consumers is dependent on a number of factors including the price elasticity of demand, the level of competition in the sector, and whether the cost increase is sector-wide or on an individual firm.

Depending on the price elasticity of demand for wet wipes, and the substitutability between plastic and plastic-free wet wipes, higher prices could lead to lower demand. However, we have assumed that cumulative demand for wet wipes would not decease and there will be no drop in overall consumption of wet wipes as a result of the ban. This has been arrived at from the following factors: any price rises are estimated to be relatively small; wet wipes are often seen a necessary product (particularly baby wipes, which make up 60% of the consumer market); plastic-free wet wipes are 100% substitutable for wet wipes containing plastic (at least for consumer wipes); and we know that low price plastic-free wet wipes are already commonly sold by retailers^[32] (allowing customers to move to a lower cost alternative if the cost of their current product of choice increases).

Through stakeholder engagement two large retailers that had switched to plastic-free for their own brand products informed us they anticipated that as more production is moved to plastic-free any retail price differential will reduce.

The ban could lead to unforeseen consequences such as lack of access to appropriate wet wipes by some groups in society. Option 1 takes a low-risk approach by exempting the sale of wet wipes containing plastic for use in business and medical settings, including to individuals, where needed for medical reasons, provided by registered pharmacies.